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Course Details

Course Information
  • smart_display Format

    On-Demand

  • signal_cellular_alt Difficulty Level

    Intermediate

  • work Practice Area

    Tax Law

Date & Time
  • event Date

    Thursday, March 25, 2021

  • schedule Time

    1:00 p.m. ET./10:00 a.m. PT

  • timer Program Length

    90 minutes

Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

$347.00
CLE
CPE
ALL

This CLE/CPE course will discuss U.S. tax law anti-hybrid rules and restrictions that may apply where U.S. and foreign tax law provide different characterizations of transaction or entity, including regulations under Section 267A and Section 245A(e).

Faculty

Devon M. Bodoh
Partner
Weil Gotshal & Manges LLP

Mr. Bodoh advises clients on cross-border mergers, acquisitions, inversions, spin-offs, other divisive strategies, restructurings, bankruptcy and non-bankruptcy workouts, the use of net operating losses, foreign tax credits, deficits and other tax attributes, and consolidated return matters.

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Anthony V. Diosdi
Partner
Diosdi & Liu, LLP

Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.

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Amanda P. Varma
Partner
Steptoe & Johnson PLLC

Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax matters, with particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, reorganizations, business restructurings, acquisitions, and financings.

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Description

The 2017 tax reform provided new anti-hybrid rules to address perceived abuse involving hybrid entities and transactions with related foreign parties. In April 2020, the IRS issued final and proposed regulations under sections 245A(e) and 267A. Tax counsel and advisers must navigate the new regulations' nuances and restrictions in international tax planning.

Section 267A denies a deduction for interest and royalties paid by a U.S. taxpayer to a related foreign party in certain situations, including when there is (1) a double-nontaxation outcome, (2) a double deduction outcome, or (3) a deduction/non-inclusion outcome.

Section 245A(e) addresses hybrid dividends received by a U.S. shareholder from a controlled foreign corporation (CFC). When applied, this provision denies a deduction for dividends received, treats similar amounts received by a CFC as subpart F income, and denies any foreign tax credit.

Listen as our panel discusses key provisions of the new regulations, new anti-hybrid restrictions, and key planning techniques for tax counsel and advisers.

Outline

  1. Overview of reasons for new rules
  2. Overview of anti-hybrid regulations under Sec. 267A and Sec. 245A
  3. Impact of the new regulations

Benefits

The panel will review these and other key issues:

  • What are the key provisions of recent IRS regulations for hybrid entities and transactions?
  • What are the key tax considerations impacting international tax planning?
  • What are hybrid deduction accounts and how do they impact a taxpayer’s dividends-received deduction under section 245A?
  • What taxpayer relief is provided under the final regulations?

NASBA Details

Learning Objectives

After completing this course, you will be able to:

  • Identify key provisions of recent IRS regulations for hybrid entities and transactions
  • Understand the impact of the new rules on international tax planning
  • Understand the special rules for hybrid deductions under the section 245A dividends-received deduction
  • Recognize the tax pitfalls of hybrid transactions and methods to avoid them

  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite: Two years+ business or public firm experience at mid-level within the organization, supervising other preparers/accountants, preparing complex individual tax forms and schedules. Familiarity with concepts of cross-border tax arbitrage and hybrid entities.

Strafford Publications, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

Strafford is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).